Last Modified October 11th, 2021

 

The Vanity Project
Privacy Policy

Our Commitment to Privacy

The Vanity Project LLC (“TVP”) is committed to respecting and protecting your privacy. TVP has developed this Privacy Policy (“Privacy Policy”) to ensure your personal information is protected. Our Privacy Policy discloses the information we gather on the Phantom platform (the “Platform”), as well as ways in which we process and, share such information and how you can correct or change such information.

This Privacy Policy addresses our privacy practices relating to the general use of our Platform by anyone who visits, browses or otherwise uses the Platform (collectively, “You”). Before submitting information to the Platform, please read this Privacy Policy. By using the Platform, submitting information, making a donation or using any of our products or services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and consent to having your data transferred to and/or processed in the United States. If you do not agree to this Privacy Policy, please do not use the Platform.

This Privacy Policy addresses what information we collected, to what extent we use any information we collect, and how long we keep it. If we change our Privacy Policy in any material way, we will obtain your consent before changing the way we use your Personally Identifiable Information.

We will implement reasonable security measures, including Secure Socket Layer (SSL) encryption technology and other tools, to protect all the information we collect about you on our websites.

The Information We Collect

TVP wants to allow users the ability to access, browse and shop the products and services we offer, and The Platform is intended to provide this great experience without requiring you to submit any more Personally Identifiable Information (“PII”) than is necessary to use the Platform effectively. We will not share your PII with third parties unless we first obtain your consent. We also will give you the opportunity of opting out of other uses that we make of any of the information you provide to us. PII that we process shall not be kept for longer than is necessary for the relevant purpose, and will process and retain such PII only as necessary for the purposes stated herein. We will retain your PII as follows:

PII will be retained for as long as you have a TVP account or as required by law or our own backup and security policies. 

We will comply with any user’s requests regarding access, correction, and/or deletion of the PII we store in accordance with applicable law, including the EU General Data Protection Regulation (GDPR). To request that we correct, delete, or export any PII, please contact us via email at [e-team@tvp.nyc]. 

We do not require you to register or submit PII in order to visit the Platform. Some activities on the Platform can be performed without providing PII. When we ask for PII, we will not require the disclosure of any more PII than we believe is reasonably necessary to participate in the activity. You can choose not to provide us with certain PII, but then you may not be able to take advantage of all of the services and products offered on the Platform. We may collect the following categories of information from you:

  • Personally Identifiable Information:  Any information collected from you by us that can used to identify you, including, your name, physical address, e-mail, phone number, fax number, and credit card information. PII also includes your browsing history if that has been linked to other personally identifiable information.
  • Anonymous Information: We collect browsing history and other non-identifiable information through the use of technology, as described further below, which is not linked to any information which would personally identify you. This information is anonymous, non-PIIA data.
  • Public Information: All information that you share about yourself in an open format (e.g., on a social network, on a third party social network application on our website, in user-generated content elements of our websites, etc.), will be considered public information. This includes information which might otherwise be considered PII if we had collected it from you.
  • Customer Information:  If you use the Platform for fulfillment services to end users, which includes generating a manual shipment, uploading a CSV file, or connecting to your e-commerce platform via API or custom implementation, we collect the information that you or the e-commerce platform passes to us, which typically includes:  end-user name, address, e-mail address and/or phone number, and products going to that end-user.

 

Your Rights Under the EU GDPR

 

Your principal rights under the EU General Data Protection Regulation (GDPR) are as follows:

  • Right of Access: you have the right to be informed of, and request access to, the PII we process about you.
  • Right to Rectification: you have the right to request that we amend or update your personal data where it is inaccurate or incomplete.
  • Right to Erasure: you have the right to have TVP delete your PII.
  • Right to Restrict: you have the right to request that we temporarily or permanently stop processing your PII. 
  • Right to Object: you have the right to object to us processing your PII on grounds relating to your particular situation or for direct marketing purposes.
  • Right to Data Portability: you have the right to request a copy of your PII in electronic format and the right to transmit that personal data for use in another party’s service.
  • Right not to be Subject to Automated Decision Making: you have the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect

Passive Gathering of Information Electronically

  • Cookies:  During the course of any visit to the Platform, the pages you see, along with “cookies,” are downloaded to your computer. A cookie is a computer file that acts as an identification card for your computer. These cookies do not contain or collect any PII, but they do enable us to provide features such as personalization. Most web browsers automatically accept cookies, but you usually can change your browser to limit or prevent cookies. Cookies in themselves do not personally identify the individual user, but rather the computer that is being used to access the Platform. You may have the opportunity to set your computer to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time. Different browsers may address cookies differently. If you set your browser to not accept cookies, it may result in certain personalized services not being provided to you when you use that computer.
  • Web Beacons: A web beacon is a transparent image file. Web beacons enable TVP to track Platform usage information, such as the number of times a given web page has been viewed. Web beacons are invisible to you and (unlike cookies) are not placed on your computer. They may be used in association with cookies to understand how visitors interact with the pages and content on the pages of the Platform. Web beacons also may be used to track whether you have opened an HTML email. When the email is opened, a part of the code that makes up the HTML page calls a web server to load the web beacon which then generates a record showing that the email has been viewed. Web Beacons may also recognize when the email was opened, how many times it was forwarded and which URL’s (links within the email) were clicked. TVP does not use web beacons to collect or otherwise record any type of PII provided by or about any User.
  • E-mail Communications: When you send an e-mail to TVP, we may retain your e-mail address and the contents of the e-mail you send.
  • Non Personally-Identifiable Information: We may also ask you to provide us with non-PII which is data that does not allow us to identify you personally, such as your first name, birthday or zip code. Your non-PII may be aggregated and used for our internal purposes or for creating reports for third-party advertisers and partners, or otherwise shared with third parties for any lawful purpose, without your permission. No third party should know who you are as a result of the use of your non-PII. We also may automatically collect Platform usage information, such as the numbers and frequency of users to the Platform, pages via Platform and similar data. This data is used in the aggregate, that is, as a statistical measure, and not in a manner that would identify you personally. Aggregate information generally is collected through the use of cookies and web beacons as discussed above. This aggregate information helps TVP determine general usage patterns and modify the Platform in order to improve your experience. This type of aggregate information may be shared with third parties at any time.

How We Use Information

When you provide us with your PII, we may use such information for a number of purposes, including:

  • To facilitate communication between TVP and you including, without limitation, responding to your questions or comments, sending e-mails concerning our products and services, or to contact you for feedback regarding us, advertisers or business partners;
  • To provide you with important functionality changes to the Platform, new TVP services and special offers from TVP and reputable third parties that we think you will find valuable;
  • To customize, analyze, adjust and improve the Platform to meet our, your, or business partners’ needs and expectations;
  • To enforce our agreements with you, prevent fraud and other prohibited or illegal activities, for other legally-permissible purposes and generally to ensure that we comply with applicable laws;
  • To utilize Public Information from third parties to provide our users as interactive media experience that brings aspects of your social networking community to the Platform.

Accessing or Changing Your PII

TVP allows you to change or correct inaccuracies in your PII by logging into your account and making changes to your PII.

Disclosure of Information To Third Parties

TVP will not give, share, sell or trade your PII to or with any third parties, except under the following circumstances:

  • Fulfillment of Services: We may partner with other companies and individuals to perform certain functions on our behalf. Such third parties may be provided with access to PII needed to perform their functions, but may not use such information for any other purpose.
  • Compliance with Law and Fraud Protection: We may disclose any information, including, without limitation, PII that we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We may also exchange information with other companies and organizations, without limitation, for credit fraud protection, risk reduction and related activities or to protect the rights, property of safety of TVP, its agents, employees or affiliates or others. TVP reserves the right to disclose PII for a user who we believe is in violation of our Privacy Policy or other terms of service as posted on the Platform, even without a subpoena, warrant, court order or other governmental request.
  • Sale or Transfer of Information: In the event of a sale, merger, liquidation, dissolution or sale or transfer of substantially all of the assets of TVP or the Platform, PII and/or other information collected about you from the Platform may be sold, assigned or transferred to the party acquiring all or substantially all of the equity and/or assets of TVP or the Platform in order to permit the party to continue the operation of TVP and/or the Platform or any successor version of the Platform. By using the Platform and providing PII to TVP, you consent to the sale and transfer of your information as described in this paragraph.
  • Credit Card Information: TVP does not collect, store or otherwise maintain any credit card information.
  • Social Commerce and Other Third Party Links: The Platform may contain links to third-party websites. Please be aware that TVP cannot control and is not responsible for the information collection practices of such websites, which may differ from those of TVP. We encourage you to review and understand the privacy policies of these web Platforms before providing any information to them.

We also may collect and store information about you that we receive from other sources, to enable us to update and correct the information contained in our database and to provide product recommendations and special offers that we think will interest you. From time to time, we may partner with trusted third parties to design and operate promotional events for our valued users. All PII and public information obtained through your participation in a promotional event will be subject to this Privacy Policy, as well as the privacy policies and practices of our promotional event partner. We will require by contract that our partners treat any PII and public information that may be obtained through a contest or promotional event in a manner consistent with this Privacy Policy.

Data Security

We maintain a variety of commercially-reasonable safeguards designed to protect your PII from unauthorized access and disclosure. For example, we use industry accepted tools and techniques to protect against unauthorized access to our systems. You should be aware, however, that TVP has no control over the security of other website on the Internet that you might visit even when a link may appear to those websites from our Platform. If you share your computer or use a computer that is accessed by the general public, remember to sign off and close your browser window when you have finished your session. This will help to ensure that others cannot access your PII.

We want you to feel confident using the Platform. However, no system can be completely secure. Therefore, although we take commercially reasonable steps to secure your information, we do not promise, and you should not expect, that your PII, searches or other communications always will remain secure. In the event of a breach of the confidentiality or security of your PII, we will notify you if reasonably possible and as reasonably necessary so that you can take appropriate protective steps. We may notify you under such circumstances using the e-mail address(es) we have on record for you. You should also take care with how you handle and disclose your PII.

Children

The Platform is not intended for persons under the age of thirteen (13) (a “Child” or “Children”). TVP does not knowingly market to, or solicit information, accept service or collect information from Children. If TVP becomes aware that any person submitting information to the Platform is a Child, we will attempt to delete the account and any related information as soon as possible. We do not permit Children to use the Platform. By using the Platform, you hereby represent that you are not a Child.

Do Not Track Policy and Procedures

TVP does not currently respond to “do not track” browser headers or specific “do not track” requests.  You do have the ability to limit tracking through these third-party programs and by taking the actions listed below.  The use of online tracking mechanisms by third-parties is governed by those third-parties’ own privacy policies, and not the terms included hereunder. If you prefer to prevent third-parties from setting and accessing cookies on your computer, you may adjust the settings of your own web browser to block the placement of cookies. You may remove yourself from the targeted advertising of companies by contacting the Network Advertising Initiative, or of companies participating in the Digital Advertising Alliance program by contacting them directly.

Your California Privacy Rights

Supplemental Privacy Notice to California Residents:

If you are a resident of California, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by TVP or its subsidiaries to a third-party for the third-party’s direct marketing purposes.  This right is granted to California residents and applies only to their activities within the State of California.  To make such a request, please send an email to: [e-team@tvp.nycl] or write us at:

The Vanity Project LLC
ATTN: CA Privacy Rights
875 Avenue of the Americas, Suite 1700, New York, NY 10001

In your request, please specify the TVP company or subsidiary to which your request pertains.  If no company is specified, we will treat your request as pertaining to The Vanity Project LLC.

Your Choices About Our Collection, Use, and Disclosure of Your Information  

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

Location Information: You can choose whether or not to allow the website to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the website may then be inaccessible or not function properly.

Targeted Advertising by TVP: If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending an email to: [e-team@tvp.nyc] requesting the same. 

Disclosure of Your Information for Third-Party Advertising and Marketing: If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by sending an email to: [e-team@tvp.nyc] requesting the same. 

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website at: https://www.networkadvertising.org/Changes to this Privacy Policy

We may occasionally update this Privacy Policy to reflect changes in our practices. When we post changes to this Privacy Policy, we will revise the updated date at the top of this Privacy Policy. If we make any material changes to our Privacy Policy, we may notify you by sending an e-mail to the e-mail address(s) you provided to us, and by prominently posting notice of the changes on the Platform. We will give you an opportunity to opt-out of any materially changed Privacy Policy or alternatively, delete the information you have provided to us. We recommend that you check the Platform from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

Users From Outside the United States

The Platform is hosted in the United States and is governed by United States law. If you are using the Platform from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Platform, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties.

 

Contacting Us

If you have any questions about TVP generally, this Privacy Policy or the Platform, please feel free to contact us either by sending an email to hello@tvp.nyc or through the “Contact Us” feature on the Platform.  Any and all Data Subject Access Requests (“DSAR’s”) may be submitted to TVP by visiting our support URL located here: tvp.nyc/contact-us and following the instructions contained therein.  Such DSAR’s shall be responded to within one month of receipt, unless applicable law requires a more expedited response.

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